This policy does not apply to any information that you may have provided to, or that is collected by, any third-party, such as restaurants or other vendors at which you were a customer. If in doubt, Repeat encourages you to consult directly with such third- parties about their privacy practices.
Company,” “Repeat,” “we,” “us,” or “our” in this Agreement refers to Repeat App USA Corp.
“Device” means any device that can access our service such as a computer, a cell phone, or a digital tablet.
“Service” refers to Repeat’s App, our website, and our related products and services.
“Website” or “App” refers, respectively, to Repeat’s website, accessible from https://www.repeat.app, and to the Repeat App, available on Apple’s App Store and Google Play.
“You” means the individual accessing or using the Service or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Your Consent to Collection and Use of Data
Collecting and Using Your Personal Data
“Usage Data” refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself. Usage Data may include information such as your Device’s IP address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.
When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers, and other diagnostic data. We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.
- Web Beacons.Certain features of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be “Persistent” or “Session” cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while Session cookies are deleted as soon as you close your web browser. We use both Session and Persistent cookies for the purposes set out below:
- Functionality Cookies are persistent cookies administered by us that allow us to remember choices you make when you use the Website, such as remembering your login details or language preference. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Website.
- Tracking and Performance Cookies are persistent cookies administered by third parties used to track information about traffic to the Website and how users use the Website. The information gathered via these cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these cookies to evaluate new pages, features, or new functionality of the Website to see how our users react to them.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
- To tell you about products or services we believe may be of interest to you on behalf of our restaurant partners
- For the purpose of requesting users’ feedback with the specific objective of improving our users’ experiences and our Services
- To help you manage your account
- To send you promotions or communications you have requested To contact you
- To provide you with information
- To manage your requests
- To maintain your setting preferences such as time zone and language
- For other purposes, such as data analysis and to improve our Service
- For the performance of a contract
- For business transfers, such as a merger of our business or sale of our assets
We may share your Personal Data in the following situations:
- With the restaurants you visit and order from to operate the Service and provide it to you.
- With business partners, to offer you certain products, services, or promotions
- With other users, when you share Personal Data that may be viewed by all users or publicly distributed by you outside our Service
- With “Service providers”—third-party companies employed by the Company to facilitate the Service—to monitor and analyze the use of our Service, for payment processing. These may include providers of hosting services, cloud services and other information technology services providers, event management services, email communication software and email newsletter services, advertising and marketing services, payment processors, logistics or delivery services, customer relationship management and customer support services, and web analytics services.
- For business transfers, such as merger of our business or sale of our assets
- To law enforcement, if required by law or in response to valid requests by public authorities
- For other legal purposes, such as protecting the company and its property and to protect others
- With your consent
Use of Anonymous Data
Our Protection of Personal Data
We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it, including physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access to your information. We also do not maintain, sell, share, rent, or lease any payment information, including credit or debit card information you may enter into the App or Website in connection with your use of the Service.
Please remember, however, your use of our Service comes at your own risk. We assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control. Do not share your user name, password, or other security information for your Repeat account with anyone. If we receive instructions using your user name and password, we will consider it authorized use of your account.
While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Transfer of Your Personal Data
Location Services Information
From time to time, our Services will require you to use one of our location-enabled services, and we may collect and process information about your mobile device’s GPS location (including the latitude, longitude, and altitude of your mobile device) Information is recorded to customize the Service with location-based information and features (for example, to inform you about restaurants in your area or applicable discounts). Some of these services require your Personal Data for the feature to work, and we may associate location data with your mobile device ID and other information we hold about you. If you wish to use this particular feature, you will be asked to consent to your Personal Data being used for this purpose. You can withdraw your consent at any time by disabling the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.
Detailed Information on the Processing of your Personal Data
The Service Providers we use may have access to your Personal Data. These third-party vendors collect, store, use, process, and transfer information about your activity on our Service in accordance with their Privacy Policies.
We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing. We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your Personal Data is governed by their privacy policies.
We may use your Personal Data to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
Data Retention and Account Termination
If you would like to delete the Personal Data we have collected from you,
permanently delete your account, please go to the Sign Out option on the app and select Delete My Account. Once your deletion request has been submitted, your account will be automatically deleted after 30 days. Alternatively, please send us an email (from the email associated with your Repeat account) to firstname.lastname@example.org.
Links to Other Websites
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers. If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information.
California Consumer Privacy Act
“Business,” for the purpose of the California Consumer Privacy Act (“CCPA”), refers to the Company as the legal entity that collects consumers’ personal data and determines the purposes and means of the processing of consumers’ personal data, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ Personal Data that does business in the State of California.
“Consumer,” for the purpose of the CCPA, means a natural person who is a California resident. A resident, as defined in the law, includes: (1) every individual who is in the US for other than a temporary or transitory purpose and (2) every individual who is domiciled in the US who is outside the US for a temporary or transitory purpose.
“Sale,” for the purpose of the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s Personal Data to another business or a third party for monetary or other valuable consideration.
For the purposes of the CCPA, “Personal Data” means any information that identifies, relates to, describes or is capable of being associated with, or could be reasonably linked, directly or indirectly, with You.
Categories of Personal Data Collected
We collect information that identifies, relates to, describes, references, or could be reasonably linked or associated, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of Personal Data which we may collect or may have been collected from California residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of Personal Data were in fact collected by us but reflects our good faith belief to the best of our knowledge that some information from the applicable category may be and may have been collected. For example, certain categories of Personal Data would only be collected if you provided such Personal Data directly to us.
- Category A: Identifiers.
- Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.
- Collected: Yes.
- Category B: Personal Data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
- Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Personal Data included in this category may overlap with other categories.
- Collected: Yes.
- Category C: Protected classification characteristics under California or federal law.
- Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, or genetic information (including familial genetic information).
- Collected: No.
- Category D: Commercial information.
- Examples: Records and history of products or services purchased or considered.
- Collected: Yes.
- Category E: Biometric information.
- Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
- Collected: No.
- Category F: Internet or other similar network activity.
- Examples: Interaction with our Service or advertisement.
- Collected: Yes.
- Category G: Geolocation data.
- Examples: Approximate physical location.
- Collected: Yes.
- Category H: Sensory data.
- Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
- Collected: No.
- Category I: Professional or employment-related information.
- Examples: Current or past job history or performance evaluations.
- Collected: No.
- Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
- Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
- Collected: No.
- Category K: Inferences drawn from other Personal Data.
- Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Collected: Yes.
Under CCPA, Personal Data does not include: (1) publicly available information from government records; (2) deidentified or aggregated consumer information; or (3) information excluded from the CCPA’s scope, such as (i) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data and (ii) Personal Data covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Sources of Personal Data
We obtain the categories of Personal Data listed above from the following categories of sources:
- Directly from You. For example, from the forms you complete on our Service, preferences you express or provide through our Service, or from your purchases on our Service.
- Indirectly from You. For example, from observing your activity on our Service.
- Automatically from You. For example, through cookies we or our Service Providers set on your Device as you navigate through our Service.
- From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors for payment processing, or other third-party vendors that we use to provide the Service to You.
Use of Personal Data for Business or Commercial Purposes
We may use or disclose Personal Data we collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:
- To operate our Service and provide you with our Service To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our Service
- To fulfill or meet the reason you provided the information. For example, if you share your contact information to ask a question about our Service, we will use that Personal Data to respond to your inquiry. If you provide your Personal Data to purchase a product or service, we will use that information to process your payment and facilitate delivery
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations
- As described to you when collecting your Personal Data or as otherwise set forth in the CCPA
- For internal administrative and auditing purposes
- To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including, when necessary, to prosecute those responsible for such activities
Disclosure of Personal Data for Business or Commercial Purposes
We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of Personal Data for business or commercial purposes: (1) Category A: Identifiers; (2) Category B: Personal Data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)); (3) Category D: Commercial information; (4) Category F: Internet or other similar network activity; and (5) Category G: Geolocation Data.
Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of Personal Data were in fact disclosed but reflects our good faith belief to the best of our knowledge that some information from the applicable category may be and may have been disclosed.
When we disclose Personal Data for a business purpose or a commercial purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract.
Sale of Personal Data
As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Data by the business to a third party for valuable consideration. This means that we may have received a benefit in return for sharing Personal Data, but not necessarily a monetary benefit.
Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of Personal Data were in fact sold but reflects our good faith belief to the best of our knowledge that some information from the applicable category may be and may have been shared for value in return.
We may sell and may have sold in the last twelve (12) months the following categories of Personal Data: (1) Category A: Identifiers; (2) Category B: Personal Data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)); (3) Category D: Commercial information; (4) Category F: Internet or other similar network activity; and (5) Category G: Geolocation Data.
Sharing Personal Data
We may share your Personal Data identified in the above categories with the following categories of third parties: (1) Service Providers; (2) payment processors; (3) our affiliates; (4) our business partners; and (5) third-party vendors to whom you or your agents authorize us to disclose your Personal Data in connection with products or services we provide to you.
Sale of Personal Data of Minors Under 16 Years of Age
We do not sell the Personal Data of Consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of Personal Data may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us. If you have reason to believe that a child under the age of 13 (or 16) has provided us with Personal Data, please contact us with sufficient detail to enable us to delete that information.
Your Rights under the CCPA
The CCPA provides California residents with specific rights regarding their Personal Data. If you are a resident of California, you have the following rights:
- The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
- The right to request. Under CCPA, you have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes and share of Personal Data. Once we receive and confirm your request, we will disclose to You:
- The categories of Personal Data we collected about You
- The categories of sources for the Personal Data we collected about You
- Our business or commercial purpose for collecting or selling that Personal Data
- The categories of third parties with whom we share that Personal Data
- The specific pieces of Personal Data we collected about You
- If we sold your Personal Data or disclosed your Personal Data for a business purpose, we will disclose to You:
- The categories of Personal Data categories sold
- The categories of Personal Data categories disclosed
- The right to say no to the sale of Personal Data (opt-out). You have the right to direct us to not sell your Personal Data. To submit an opt-out request please contact us.
- The right to delete Personal Data. You have the right to request the deletion of your Personal Data, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our Service Providers to delete) your Personal Data from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our Service Providers to:
- Complete the transaction for which we collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.)
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us
- Comply with a legal obligation
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it
- The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer’s rights, including by:
- Denying goods or services to you
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to you
- Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services
Exercising Your CCPA Data Protection Rights
In order to exercise any of your rights under the CCPA, and if you are a California resident, you can contact us by visiting this page on our website: https://www.repeat.app/contact-us/. Only You or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your Personal Data. Your request to us must: (1) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative; and (2) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with the required information if we cannot verify your identity or authority to make the request and confirm that the Personal Data relates to you.
We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice. Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt. For data portability requests, we will select a format to provide your Personal Data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
Do Not Sell My Personal Data
You have the right to opt-out of the sale of your Personal Data. Once we receive and confirm a verifiable consumer request from you, we will stop selling your Personal Data. To exercise your right to opt-out, please contact us. The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells Personal Data as defined by the CCPA law. If you wish to opt out of the use of your Personal Data for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below. Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.
Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests: (1) “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices; and (2) “Limit Ad Tracking” on iOS devices. You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services, or applications to request and obtain removal of content or information they have publicly posted. To request removal of such data, and if you are a California resident, you can contact us using the contact information provided below and include the email address associated with your account. Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Your California Privacy Rights (California’s Shine the Light law)
Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes. If you would like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided below.
“Do Not Track” Policy as Required by California Online Privacy Protection Act (“CalOPPA”)
“Do Not Track” or “DNT” is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission, for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites. Our Service does not respond to Do Not Track signals. However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
General Data Privacy Regulation
Legal Basis for Processing Personal Data
Under the General Data Privacy Regulation (“GDPR”), “you” can be referred to as the data subject or as the user as you are the individual using the Service. For the purposes for GDPR, Personal Data means any information relating to you, such as a name, an identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity. “Service Providers” are considered Data Processors.
We may process Personal Data under the following conditions:
- Consent: You have given your consent for processing Personal Data for one or more specific purposes.
- Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
- Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
- Vital interests: Processing Personal Data is necessary to protect your vital interests or of another natural person.
- Public interests: Processing Personal Data is related to a task that is conducted in the public interest or in the exercise of official authority vested in the Company.
- Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter a contract.
Your Rights under the GDPR
- Request access to your Personal Data,including the right to access, update, or delete the information we have on You. If you are unable to perform these actions yourself, please contact us to assist You.
- Request correction of the Personal Data that we hold about you.
- Object to processing of your Personal Data.
- Request erasure of your Personal Data.
- Request the transfer of your Personal Data held as automated information which you initially provided consent for us to use or where we used the information to perform a contract with You.
- Withdraw your consent. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.
Exercising of Your GDPR Data Protection Rights
You may exercise your rights of access, rectification, cancellation, and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, if you are in the European Economic Area (“EEA”), please contact your local data protection authority in the EEA. For the GDPR, the Company is the Data Controller for use of the Service. A “Data Controller” is the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.